If you are a client of Monnos’ services or just visiting our website, this Policy applies to you. Please, read this carefully. Monnos aims to simplify the use of Crypto by bringing usability to it, blending Exchange and Wallet functionality into a one solution at your mobile.
1. Our Responsibilities
We act as a “Data Controller” (for GDPR) or as a “Controlador” (for LGPD) of your personal data, if you are a client or a visitor to our website. This means that we determine how and for what purpose your data will be processed. We are registered as a Data Controller before the Federal Data Protection and Information Commissioner (FDPIC).
2. Your responsibilities
Monnos is a business service directed to and intended for use only by those who are 18 years of age or over. We do not aim at children, and we do not knowingly collect any personal data from any person under 18 years of age.
4. Location of the services offered
4.1. If you are a client or a visitor located in Europe, this policy applies, as well as the specific sections regarding the European legislation, i.e., the General Data Protection Regulation (GDPR).
4.2. If you are a client or a visitor located in Brazil, this policy applies, as well as the specific sections regarding the Brazilian Data Protection Legislation (Lei Geral de Proteção de Dados – LGPD).
5. How and when we collect your data
We might collect data directly from you, especially if you are a client and agreed with the contract between us for the purposes of the services you agreed with us to be provided at our APP. We may also collect information automatically, in case you browse our website or when we send an e-mail to you.
5.1. For the services we provide to you, in case you choose to enroll to our website and our services, we will collect your data to execute the contract between us and to create your registry, and also comply with anti-money laundering and similar legislation.
6. Types of data we collect
we collect and/or receive from you your contact information, financial information, and other data, as follows.
a. Contact information: The information that we collect depends of how big is the amount of crypto or Fiat money that you will use at our platform, but it will include at least your name, date of birth, address, e-mail, telephone number, identity’s number, declaration of being or not a Politically Exposed Person.
b. Financial information: Your bank account number. The credit card details will be checked by our partner, we will never store it. We might also request other information in accordance with our PLD program. We might also ask for further information, for security purposes, so as to prevent fraud and for risk of the credit assessment.
c. Other data we collect or receive from you: Login information, IP address, geolocation information, time zone setting, operating system, and version, type of browser and version, browser plug-in types. We also collect on how you use our website, such as the pages you visit and the paths you take, what do you do in each page, how long you stay in each page, services viewed, and other actions.
7. Sensitive data
We do not collect sensitive data from you. For Europe and the GDPR, sensitive data means racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offenses or alleged offenses.
8. How we use your data and for what purpose
a. Providing our services: Processing your data to provide the services you are agreeing with us and at your request. Legal basis: Contract.
b. Your Registry (KYC – know your client – procedure): Collecting and processing your data is necessary to comply with our Compliance and KYC procedure. Your data may be shared with the appropriate authorities to comply with anti-money laundering and similar legislations. Legal basis: Legitimate Interest (Fraud Prevention – GDPR) / Legal Obligation / Credit Protection (LGPD).
c. Assisting you (Customer Support): Solving issues by e-mail, phone or chat, interacting with you to notice any changes to our services or any bug fixing. Legal basis: Contract.
d. Marketing: E-mails and messages sent to you with content related to your services and also about new services, products or features. Legal basis: “Legitimate Interest” (Legítimo Interesse). 3
e. Improving our website and services: Testing features, traffic optimization, managing pages of our website, heat map of our website, data analysis, and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this. Legal basis: Contract
9. Legal basis
Besides the specific purpose, we must have also a legal basis to collect and process your data. Thus, you can find below the hypothesis under which processing your data for the purposes we are informing you is legal.
a. Contract: When processing your data is necessary for a contract you have with us, or because we have asked you specific information to complete your registry with us before agreeing with the contract.
b. Legal Obligation: Processing your data is necessary because a law or regulation demands we do so.
d. Legitimate Interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, but only if we balance them with your rights and interest. It includes the actions we listed above in Improving our website, services, and Marketing and also fraud prevention and the security of our services.
You can exercise your rights by sending us an email at email@example.com or by accessing your registry in our APP.
11.1. You have the right to confirm we have data about you, to access and be informed about what information (if any) we have about you, and you can also ask us more information about: a. The purposes of the processing of your data. b. The categories of data being processed. c. Third parties to whom the data may be shared or transferred. d. How long your data will be stored (or the basis we used to determine how long we will store it). e. The other rights you may have including those listed in this section.
11.2 You also have the following rights: a. Right to update or correct your information within us, accessing your registry page in our website to change, updating or correcting any information. If you are not able to do so, please contact us by e-mail (firstname.lastname@example.org) b. Right to oppose to the use of your data for direct marketing, by opting-out on your registry page in our application (“APP”). c. Right to have a copy of your data in so that you can provide it to another service (portability). d. Right to delete your data (right to be forgotten), asking us to erase any personal data we hold about you. Your information can be deleted if we do not have to maintain such information for the purposes of the services you have with us (e.g. we might have to keep your data to comply with specific legislation). Please contact us by e-mail (email@example.com) 5 e. Right to file a complaint. We kindly ask that you contact us in order to handle any problems you might have. If we fail to address your concern, you can file a complaint to the Federal Data Protection and Information Commissioner (FDPIC), either by e-mail or calling them on Tel. +41 (0)58 462 43 95 (from Monday to Friday from 10am to 12pm) or as directed on their website at https://www.edoeb.admin.ch/edoeb/en/home/thefdpic/contact.html.
11.3 We will provide you with the information of your request as soon as we can, respecting the 30 days term for persons located inside European territory as provided for under the European legislation. We will let you know the reasons in case we cannot respond to your request.
11.4 We may inform you that additional time is necessary, in case the request is complex. It may also take more time to completely respond to you if that could significantly impact the rights and freedoms of other people.
12. Where do we store and process your data
12.1 Your data is also processed by third parties in the data processing facilities identified below (Third Parties We Work With).
JUMIO (Palo Alto – EUA) – Responsible of the flow of the Onboarding Digital;
AWS (Amazon Web Services) – Responsible for our cloud.
13. How long do we store your data
Also, we will delete your personal data from our files after 5 years from the last time you used our services or as agreed with you in the service contract. We will also delete your data if you request us to do so, as described above and unless no other reason exists.
14. How secure is the data we collect
We have physical and electronic procedures to safeguard and keep the information we collect safe, and that includes internal politics. Also, you are responsible for securely keeping your login, password and other information needed to access this website. In case you have reason to believe that your data has been exposed, please contact us by e-mail, on firstname.lastname@example.org
15. Third Parties We Work With
Like any other digital service provider, we use other companies to assist us with specific tasks, such as hosting the website, marketing, storing information, sending e-mails, etc. By using them, we might share some of your data to perform specific tasks, for the purposes we described above (How we use your data and for what purpose). That means that we only share the information that is necessary for them to do their job and for the tasks, we ask them to do, following the policies of Monnos. 6
15.1 In the case of third parties located outside the EEA (or Brazil, as applicable), we use the same security level, as explained above (Where do we store and process your data). In case the company we share is located in the United States of America (USA), we make our reasonable efforts to ensure that the organization in question has a current certification with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce’s International Trade Administration (ITA).
Cookies are used to collect information about how you use and interact with a website. There are two types of cookies. The session cookies, that last during the session and self delete when you leave the webpage. The persistent cookies do not delete themselves but help a website recognize you when you come back, to improve your experience.
MONNOS PLATFORM TERMS AND CONDITIONS OF SERVICE
Last Updated September 5, 2019
READ WITH ATTENTION
BY REGISTERING ON THE MONNOS PLATFORM, YOU AGREE TO ALL TERMS OF SERVICE DESCRIBED AS FOLLOWS. BEFORE ACCEPTING THESE TERMS OF SERVICE, MAKE SURE YOU UNDERSTAND YOUR FULL CONTENT.
MONNOS PLATFORM IS NOT A DISTRIBUTOR OF SECURITIES. HENCE, NO TOKEN MIRRORED IN THE PLATFORM REPRESENTS AN EQUITY, COLLECTIVE INVESTMENT CONTRACTS, TRANSFERABLE SECURITY OR ANY OTHER TYPE OF SECURITY.
ALL CRYPTOCURRENCY EXCHANGE STRATEGIES ARE ONLY AND EXCLUSIVE THE USER’S RESPONSIBILITY. YOU SHOULD NOT DO ANY TRADE IF YOU DO NOT UNDERSTAND THE RISKS INVOLVING THE NATURE OF THESE TRANSACTIONS.
OUR PRODUCTS AND SERVICES ARE NOT OFFERED FOR USE IN THE UNITED STATES OF AMERICA, ITS TERRITORIES OR POSSESSIONS, INCLUDING ANY PERSON FROM THE UNITED STATES OF AMERICA, CITIZENS OF THE UNITED STATES OF AMERICA, PERMANENT RESIDENTS OF THE UNITED STATES OF AMERICA (EG, GREEN CARDS OWNERS) AND COMPANIES ESTABLISHED UNDER THE LAWS OF THE UNITED STATES OF AMERICA OR ANY PERSON RECOGNIZED AS ‘US PERSON’ UNDER RULE 902 (K) (1) REGULATION ‘S’.
FURTHERMORE, THE PRODUCTS AND SERVICES AVAILABLE ARE NOT OFFERED FOR USE IN ANY COUNTRY OR JURISDICTION OR TO ANY PERSON WHICH THE USE OF THE SERVICES OFFERED BY MONNOS CONSTITUTES AN INFRINGEMENT OF THE LAW OR REQUIRES SPECIAL AUTHORIZATION THAT MONNOS DOES NOT HAVE.
MONNOS PRODUCTS AND SERVICES ARE ONLY AVAILABLE FOR THOSE WHO HAVE THE PROPER CAPACITY, POWERS OR LICENSES TO ENJOY THEIR FUNCTIONS. BY MAKING YOU REGISTER WITH MONNOS YOU HAVE DECLARED TO HAVE ALL THE LEGAL PRE-REQUIREMENTS IMPOSED BY YOUR HOUSEHOLD JURISDICTION TO ENJOY MONNOS SERVICES AND PRODUCTS FREELY AND LAWFULLY.
These Terms and Conditions of Service (“Term” or “Terms”) rules access and use by Monnos Platform Users (“user” or “you”). The Kryeg Soluções Digitais EIRELI company maintains the platform (trade name: MONNOS), a company incorporated under the Brazilian laws, enrolled with the CNPJ (National Register of Legal Entities) under the number 31238023/0001-62 (“Monnos,” or “our”).
1.1. By the word “service”, it should be understood as the access to the Monnos Platform through the site http://monnos.com and http://monnos.com.br and across applications (“Apps”) for iOS or Android ( together, “Platform”), effected through registration in the respective virtual environments.
1.2. Monnos offers its users an intermediary platform for buying and selling crypto assets. Through the platform, the user has access to competitive prices in the global market, being integrated into several exchanges through the Exchange Hub system. Also, in the Monnos Platform, you can access other features described in item 7.
1.2.1. Monnos do not purchase or sell crypto assets, allowing in its platform the approach between users, which can buy and sell digital assets, according to their preferences. Besides that, other features described in item 7 are offered.
1.3. Monnos does not offer its services in jurisdictions where such distribution, publication, or use would be contrary to law or regulations or even which Monnos does not hold proper registration or necessary license to operate. The individuals or entities subject to these prohibitions, either because of their nationality, their place of residence, or for other reasons, must not access or use the platform.
By agreeing to these Terms, the User acknowledges that have 18+ years of age or civil majority by the laws of his State of residence and/or nationality, having the full civil capacity to be a party to and adhere to these Terms.
The Terms may at any time be amended by Monnos due to (i) legislative updates, (ii) services updates, (iii) technology updates, (iv) Monnos internal policy updates, (v) changes in the Monnos economic group or as a result of other corporate matters involving modification of the service providers or owners of the intellectual property necessary to provide Monnos’ services, as well as any other issues affecting the legal relationship between Monnos and its members. The Terms may also be modified for Monnos convenience at any time. Users will be notified of updates within the platform. If the platform continues to be used after the revised date, the amendments to the Terms are considered accepted. If the user does not agree to any of the changes made to these Terms, then he must stop using the Monnos Platform.
6. Money Laundering Prevention and Terrorist Financing Policy.
Monnos users must complete the form according to the value of their transactions and the source of their resources, pledging to answer Monnos questions whenever requested.
6.1. The user undertakes to provide accurate, current, and complete information and commits always to keep it updated.
6.2. Monnos is not responsible for the information provided by each user, and this information is provided under the sole responsibility of the user.
6.3. Providing false information or misusing third-party data in its own name is a criminal offense. In any of these cases, Monnos may permanently suspend or terminate the relevant user’s access to all platform services and features without prior notice and prejudice to other measures provided by applicable law.
6.4. Monnos may, at its sole discretion, request additional documents and information to confirm or maintain access to any user. If Monnos decides to exercise this right for any user, that user’s access may be suspended or permanently terminated if that user refuses to provide the required information or documents or if it turns out, upon examination of such information and documents, that the user has entered false or incomplete information.
6.5. Monnos reserves the right to refuse any request for access and to suspend or cancel immediately any previously granted access in cases (i) violation of any provision of these Terms of Service, (ii) unverifiable identity or misrepresentation of any information provided by the user, (iii) the user engages in fraudulent or malicious acts or engages in any behavior that, at Monnos’ discretion, is incompatible with the platform’s policy and objectives, the ethical rules of coexistence and urbanity with other users or that may result in any way cause damage to third-parties or the platform.
6.6. Monnos reserves the right to unilaterally terminate the relationship with their users, suspending access to the platform, due commercial indifference, in compliance with prior notification of not less than three working days, and other necessary measures to prevent damage to the user.
Monnos will introduce an integrated user interface that intermediates with several buying and selling crypto assets and other digital assets companies based on blockchain technology (Exchange Hub). In addition to the proximity between users who purchase and sell crypto assets, it is also possible to enjoy features such as Wallets, Sync Strategy, and Crypto Saving Account defined respectively in items 7.1, 7.2, and 7.3.
7.1. Wallets. The platform allows users to create one or more wallets, according to their strategies. The user may compose his portfolios with the crypto of his choice available for trading, following his individual goals and market beliefs. An unlimited number of cryptocurrencies can be allocated to each of the user-created portfolios, which must select a base currency to display the consolidated balance.
7.2. Sync Strategy. Within the platform, users may change the status of their wallets to “public”. Every wallet born as private, i.e., visible only to its owner and may later become public.
7.2.1. When a wallet goes public, it goes through category, ranking, and reputation indexing algorithms.
7.2.2. By selecting the public wallet mode, the user agrees that other users can follow his strategies.
7.2.3. By choosing to follow a strategy, the user agrees and declares to be aware that all moves of the strategy owner will be performed automatically in his wallet at the selected rate. Also, it claims to be aware of the risks involved in any crypto assets allocation and assumes sole responsibility for any loss of the amounts invested. The user also agrees that part of the gains and equity increases resulting from the success of the strategies followed will be directed to the strategy owner and Monnos, under percentage conditions previously defined by Monnos and available on the platform.
7.2.4. By choosing to follow a strategy, the user is aware of the costs involved in any trade performed by the portfolio owner, and that these fees will be divided proportionally between both, user and the owner of the strategy.
7.3. Crypto saving account. When choosing to use the platform, the “Crypto saving account” feature will be automatically activated; thus, the user authorizes and declares to be aware of the following:
7.3.1. The user, as the lender and legitimate owner of the crypto assets available on the Monnos Platform, agrees to lend to Monnos, for an indefinite period (while using the platform), the total assets he has, whenever Monnos realizes the possibility of using the “Crypto Saving Account” feature.
7.3.2. During the loan period, Monnos, in case of gains, will reward the user in a predefined percentage weekly on the platform, without any fixed or variable return guarantee, being a randomized result contract.
7.3.3. The user may leave the loan, withdrawing its values from the platform at any time.
7.3.4. If there is no express indication of withdrawal of values, if the user continues to make their crypto available on the Monnos Platform, the loan will be considered adequate during the application of the ‘Crypto Saving Account’ and will produce all its typical effects.
7.3.5. The Monnos undertakes to return to the user, whenever required, the balance of virtual currency in the present applicant user’s portfolio, plus compensation, if any, as defined in item 7.3.2., without commitment of returning the original volume virtual currencies or of the deposited types of crypto initially, considering the acceptance of the risks listed in items 10 and 11.
7.3.6. The availability of the borrowed balances with Monnos will occur as follows: (i) upon express withdrawal, Monnos delivers the loaned crypto assets within 48 (forty-eight) hours; (ii) the additional amounts will be made available weekly, regardless of the withdrawal request, including current residuals if any.
8. The Monnos Token.
Monnos issues the coins to its users within the platform. The issuing of such tokens occurs in specific situations. The Monnos tokens issuance assumptions, along with incentive forecasts for the use of Monnos tokens within the Monnos Platform are as follows:
8.1. Bonus program / Use and Win. The user participates in a reward system for use. For any amount spent on the platform, the user can earn Monnos tokens. The number of tokens received varies according to a dynamic mathematical formula, which has as one of its variables the value spent on exchanges within the platform. The user does not earn Monnos tokens when paying with his Monnos token. This bonus may or may not be available under Monnos strategic assessment.
8.2. Payment Discount Made with Monnos Tokens. Users who pay for services offered by the Platform with Monnos tokens receive a discount on payment for these services. The Monnos team will set these discounts at any time;
8.2.1. Monnos Actions and Promotions. The Monnos can launch at any timeshares and promotions aimed at users who earn Monnos tokens and making use of certain features that may be aligned with the strategy of boosting the company.
9. Fees and Commissions.
The app download and access to the platform are free. Fees will be charged for the use of certain features within the platform, the values of which are provided in this link. Click here to see conditions Monnos.
9.1. All Monnos pricing policies may be reviewed, updated, and adjusted at the sole discretion of the Monnos team. Policy modifications and price adjustments and updates will be communicated appropriately on the platform. If the user does not agree with the pricing policy modifications or changes and updates, the user should stop using the Monnos Platform.
10. Risks associated with using the platform.
The user, in agreeing to these Terms, declares to be aware of the risks involving the option to apply their crypto in the Sync Strategy function, in the operations involving Crypto Saving Account and other options available on the platform, assuming responsibility for any losses arising from such choices made, according to item 11.
11. Limitation of Liability and User Obligations.
Monnos indicates that activities in the platform are considered very high-risk activities, implying the acceptance by the user of the possibility of financial losses by manipulating crypto assets and other digital assets based on the blockchain technology using the platform. By using the platform, the user is aware of the risks that the use of cryptocurrencies entails. The Monnos is not responsible for any losses caused as a result of speculative activities performed by the user concerning the cryptocurrencies market, even if such activities are carried out through or from the platform. Monnos is not responsible for any losses in the user total cryptocurrencies amount due to third party act of self-positing at risk by unforeseeable circumstances, force majeure, or the risks inherent in the application of cryptocurrencies the option Sync Strategy or any other functionality market speculative and/or because of the options the user selects on the platform. The user declares he is aware of the risks involving the applications and is outside Monnos scope of action. The user may question difficulties of technical and technological origin through the Customer Service System or by contacting them directly by email available on the platforms. IN NO EVENT SHALL MONNOS BE LIABLE FOR ANY LOSS, DAMAGE, LOSS, OR PROFIT LOSS, WHICH YOU MAY DUE TO TRADING OR UNDERTAKING THROUGH THE PLATFORM.
11.1. Monnos is not responsible for any errors committed by the user in the registration of their bank details or address wallet.
11.2. Monnos is firmly committed to using its best efforts to engage the platform exchanges with a high degree of security, transparency, and trust. However, Monnos shall not be liable for any damages arising from failures, errors, or any other acts or facts occurring by or from the exchanges attached to the platform, whether related to functionality as well as civil and/or criminal liability.
11.3. Platform services are subject to interruptions, delays, and problems inherent in internet use. Monnos shall not be liable for any such disruptions, delays or issues, or for any defects or limitations of equipment or the browser used by the user or even for any faults or flaws of access provision of services or infrastructure access internet contracted by the users. Monnos will not be responsible for any viruses that may attack the user equipment as a result of access, use or browsing the Internet or as a result of the transfer of data, files, images, text or audio.
11.4. Monnos does not act and cannot act as a consultant, including financial, legal, investment, insurance, and/or tax. Any information provided by Monnos or achieved through the platform’s features is considered general information and is not a substitute for consulting the expert in the respective area. The user is solely responsible for the options he selects.
11.5. Monnos will not be responsible for delays, failure in performance or interruption of the services resulting directly or indirectly from any causes or conditions that are outside its reasonable control, including but not limited to, any delay or failure due to the occurrence act of God or Force Majeure, acts of civil or military authority, acts of terrorism, civil disturbance, war, strike or other labor dispute, fire, interruption of telecommunications or Internet services or network provider services, equipment failure and / or software, other catastrophe, or any other occurrence beyond Monnos’ reasonable control .
11.6. The user agrees and represents that he will not use the Monnos Platform to engage in any illegal activity or to take any action that adversely affects the performance of the platform. The user may not engage in any of the following activities through the platform, nor may assist any third party in any of the following actions: (1) attempt to gain unauthorized access to the Monnos Platform or another user’s account, (2) make any attempt to bypass or circumvent any security features, (3) violate any law, statute, ordinance or regulation, (4) reproduce, duplicate, copy, sell or resell the Monnos Services for any purpose except as authorized in these Terms, (5) participate in any activity deemed abusive, which interferes with or disrupts the functionality of the platform. If the user is blocked by Monnos and is unable to access the platform (including due to blocking his IP address), the user agrees not to take any measures to circumvent such blocking (for example, by masking his IP address or using a proxy IP address). THE USE OF THE MONNOS PLATFORM IN CONNECTION WITH ANY TRANSACTION INVOLVING ILLEGAL PRODUCTS OR SERVICES IS PROHIBITED.
11.7. Monnos reserves the right to restrict the use of the platform or suspend temporarily or permanently the user’s account in the event of any violation of this section, without prejudice to other appropriate legal action.
12. Refund and reversal.
Once the transaction has begun, in the case of a brokerage in the purchase and sale of crypto assets, as well as any other functionality available in the platform, it is not possible to reverse. Similarly, payments and/or transfers related to such transactions are not redeemable. Therefore, the reversal within the platform of any transaction already started is not possible, nor is there any right of redemption against Monnos.
13. Intellectual Property Rights.
Users acknowledge and agree that Monnos is the sole and exclusive owner of all copyright and intellectual property related to the platform, including domain name, programming, files, databases, content, design, features, and other features, and that such rights are protected by law. The trade name Monnos, the brand Monnos and the products and services corresponding to the trademark are the sole property of Monnos, and unauthorized use is subject to the consequences provided by law.
13.1. These Terms of Service do not imply the assignment or transfer to the user of any rights relating to the platform, or any part of its content or features. Users may use the platform only in strict terms permitted in these Terms of Service.
13.2. Users are prohibited from modifying or attempting to alter any functionality of the platform, to produce any derivations of the products and services offered by the platform, or to access any part of the platform for the purpose of creating a competing product or service, or any product or service containing ideas, characteristics or functions similar to those of the platform.
13.3. Also, the use of any device, software, or other feature that may interfere with the Platform activities and operations or that is intended for improper access to Platform information or databases is not permitted.
13.4. Any activity that violates or contravenes intellectual property laws, other applicable rules or the prohibitions outlined in these Terms of Service will subject the party to the legal consequences of the relevant jurisdictions, including the refund for any damages caused.
13.5. The platform may display links to other Internet sites, which does not mean that such sites are owned or operated by Monnos.
13.5.1. Monnos has no control over the content of other sites to which links embedded in the Platform Monnos facilitate access, and thus will not be responsible for the content, practices, and services offered in these other sites.
14. Final provisions.
14.1. If for any reason a court of competent jurisdiction finds any provision of these Terms to be invalid or unenforceable, that provision shall apply to the fullest extent permissible, and the other provisions of these Terms shall remain in full force and effect.
14.2. In the event of a breach of any provision of these Terms of Service, Monnos may terminate its relationship with that User, regardless of any notice, notification or other formality, immediately terminating his access to the platform, without prejudice to any other rights granted to Monnos by law or these Terms of Service.
14.3. Monnos’ failure to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.
14.4. The Monnos may assign these terms and control platform to its affiliates or subsidiaries, present, and future, or in connection with a merger, consolidation, sale or other disposition of all or substantially all of its assets. These Terms, together with any other agreements that apply to the User, constitute the entire and exclusive agreement between Monnos and the User concerning the subject matter and supersede any prior or contemporaneous written or oral agreement, warranty, or representation regarding the user subject matter.
14.5. These Terms of Service are governed by the laws of the Federative Republic of Brazil, and the forum of the Capital of the State of São Paulo is as a result of this excluded, except as privileged as it may be, to settle any disputes or disputes from these Terms of Service.
THE USER ACKNOWLEDGE THAT THE FEATURES OF USE OF THE PLATFORM AND THE SERVICES AVAILABLE THEREIN ARE SUFFICIENTLY DESCRIBED IN THESE TERMS, AND MONNOS HAS COMPLIED WITH THE DUTIES OF INFORMATION. AFTER READING ALL CONDITIONS GOVERNING THE USE OF THE PLATFORM AND ITS SERVICES, THE USER CONSENT TO THESE TERMS OF SERVICE AND ACCEPT ALL ITS PROVISIONS.
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1. O PROGRAMA DE COMPLIANCE
A Monnos possui uma Política de Prevenção à Lavagem de Dinheiro e ao Financiamento de Ilícitos e Terrorismo (PLDFIT) efetiva. As atividades da Monnos são pautadas pelo teor de sua Política PLDFIT, sempre em evolução e em sintonia com as características do seu mercado, assim como por imperativos legais, normativos e éticos aplicáveis à sua atividade. Desta forma, a Monnos assegura aos seus clientes e órgãos reguladores e aos demais integrantes do Mercado a lisura de suas operações. A Política PLDFIT é estruturada de forma a combater o cometimento de ilícitos, dividida em diferentes componentes que convergem para este propósito. Como as demais entidades do sistema financeiro, a Monnos preza pela identificação de seus clientes – identificação esta que deve ser mantida atualizada –, em harmonia com recomendações da Financial Action Task Force (FATF) e do Bank for International Settlement (BIS). Com efeito, pessoas identificadas como politicamente expostas terão tratamento diferenciado pela equipe Monnos. Outro pilar da Política PLDFIT é o registro e identificação das transações. Em se tratando de mercado onde transações ocorrem em montantes e velocidade significativos, não se pode ignorar o potencial para práticas ilegais. Desta maneira, a Monnos se mantém atenta às movimentações financeiras realizadas sob sua supervisão – sejam elas entre criptoativos, sejam elas entre criptoativos e moedas fiduciárias –, sempre disposta a colaborar com autoridades competentes caso haja suspeita de violação à lei. Ressalta-se, ainda, que a Monnos não recebe dinheiro em espécie, garantindo-se assim transparência e documentação das transações. De igual importância é o preparo da equipe. Para além dos envolvidos diretamente com o setor de compliance, todos devem estar a par de indícios de cometimento de ilícitos e dispostos a identificar e relatar tais comportamentos ao setor competente. A cultura de compliance é reforçada por todos da equipe Monnos; de seu CEO ao mais novo empregado, todos compreendem a relevância da Política PLDFIT. Ainda neste campo, as transações a serem realizadas na Monnos respeitarão a limites correspondentes ao grau de documentação do cliente. Isto é: para movimentar montantes mais elevados, os clientes Monnos deverão se submeter a maior escrutínio, podendo ter seu pedido de expansão de limite negado. Novos documentos podem ser pedidos a qualquer momento, e a colaboração com as demandas é essencial. Estes fundamentos ora apresentados de maneira alguma encerram a Política PLDFIT da Monnos; demonstra-se aqui tão somente o grau de compromisso da Monnos com o cumprimento da lei e seu apreço pela boa-fé e transparência.
2. RISCO DO MERCADO DE CRIPTOATIVOS
Criptoativos não são moeda fiduciária. Isto significa que não são regulados por nenhum banco central ou outra entidade governamental e, a depender de suas características, podem não possuir qualquer valor intrínseco. O risco de perdas financeiras é fator a ser considerado durante qualquer operação.
3. NORMAS APLICÁVEIS
As normas jurídicas que regulam o mercado de criptoativos ainda são escassas. No entanto, a Monnos se mantém em harmonia com ditames legais reguladores do mercado financeiro tradicional. Buscando mitigar os riscos de cometimento de ilícitos – financeiros ou não –, a Monnos desenvolveu seu programa PLDFIT observando recomendações e leis de diferentes órgãos e jurisdições. É válido ressaltar que a Monnos não é instituição financeira tradicional, motivo pelo qual, a princípio, as normas dedicadas a empresas deste segmento não são integralmente aplicáveis à Monnos. No entanto, por entender que o combate a ilícitos é objetivo comum de todos, a Monnos está em constante busca e implementação dos ditames que melhor conduzem a este fim. Todo e qualquer pedido de cooperação de autoridades, quando razoável e legítimo, será atendido pela Monnos. Igualmente, o cometimento de ilícitos não será tolerado, havendo correspondente denúncia aos órgãos competentes. A Monnos se reserva o direito de recusar ou encerrar relacionamentos com qualquer pessoa ou entidade que não esteja em sintonia com seus princípios éticos, com seus Termos de Uso, com sua Política de Dados, com sua Política de Prevenção à Lavagem de Dinheiro e ao Financiamento de Ilícitos e Terrorismo, ou com qualquer outro documento que indique os parâmetros de atuação da Monnos.
4. PAÍSES NÃO ATENDIDOS
Por motivo de risco inerente às operações com estes Estados, a Monnos não atenderá as pessoas físicas ou jurídicas residentes, sediadas ou com dependência nas seguintes jurisdições: Afeganistão, Arábia Saudita, Bahamas, Botswana, Camboja, Coreia do Norte, Etiópia, Gana, Guam, Guiné- Bissau, Iêmen, Ilhas Virgens Americanas, Irã, Iraque, Líbano, Líbia, Mali, Nigéria, Panamá, Paquistão, Porto Rico, República Centro-Africana, República Democrática do Congo, Samoa, Samoa Americana, Sérvia, Síria, Somália, Sri Lanka, Sudão, Sudão do Sul, Trinidade e Tobago, e Tunísia. Por sua vez, pessoas com conexões com Estados dos Balcãs – Albânia, Bósnia e Herzegovina, Bulgária, Grécia, Macedônia do Norte, Montenegro, Sérvia, Kosovo, Croácia, Romênia e Eslovênia –, Bielorrússia, Burundi, Cuba, Nicarágua, Ucrânia, Venezuela e Zimbábue deverão passar por procedimento de cadastro diferenciado. Finalmente, independentemente da exclusão das jurisdicões supracitados, as operações Monnos não são disponibilizadas para residentes nos Estados Unidos da América ou China.
5. COOPERAÇÃO COM AUTORIDADES PÚBLICAS
A Monnos preza pela cooperação com órgãos públicos no combate à corrupção, lavagem de dinheiro e financiamento de terrorismo. Qualquer autoridade pode contatar a Monnos com o objetivo de cumprir determinações legais, judiciais ou regulamentares por meio do seguinte canal: email@example.com ou firstname.lastname@example.org.
Qualquer pessoa que tome conhecimento de práticas ilícitas que, de qualquer forma, envolvam a Monnos, deve comunicar imediatamente à Monnos pelos canais de comunicação internos, em especial, o seguinte endereço de e-mail: email@example.com ou firstname.lastname@example.org São aceitas denúncias anônimas, desde que sejam corroboradas com provas ou indícios que permitam que a equipe interna elucide os fatos.
7. DECLARAÇÕES FINAIS
A Política de Prevenção à Lavagem de Dinheiro e ao Financiamento de Ilícitos e Terrorismo, em sua integralidade, está disponível apenas para aqueles que mantenham relação de extrema proximidade com a Monnos, em virtude da necessidade de sigilo das medidas de compliance adotadas. A recusa em fornecer quaisquer documentos ou informações solicitados pela Monnos poderá conduzir ao encerramento da relação, sem que para isso sejam apresentadas maiores razões. Na existência de um mesmo documento com traduções em diferentes idiomas, a versão em português prevalecerá. Atualização em 09 de Setembro de 2019.